Fighting The NAP Nativist Agenda

Once in a while, we want to affirm the values that San Francisco Forest Alliance stands for. We’re a grass-roots organization of people who love nature and the environment, pay taxes responsibly, and want access to our parks and wild places – with our families.

Citizens care about their city Parks, and want to keep healthy trees and to open access to natural areas. Citizens expect city management to act responsibly and in the public trust, for FAIR allocation of 2008 Clean & Safe Neighborhood Parks Bond funds.

SF Recreation and Parks Department (SFRPD) and particularly the Natural Areas Program (NAP), obsessed with Native Plants, is cutting down trees, restricting access, using more toxic herbicides than any other section of SFRPD (excluding Harding Park Golf Course), and using financial resources that could better be used for things our city’s residents really want.

OUR VIDEO

Watch our video on Youtube, (where you can also sign up for the SF Forest Alliance Youtube channel):

OUR MESSAGE TO SAN FRANCISCO AND SFRPD

What we stand for can be summarized in four key areas: Trees, Access, Toxins, Taxes.

 

Help us save the urban forests in our San Francisco Parks

Glen Canyon Park: One Year after Start of Tree Destruction

The Glen Canyon Playground and Tennis Court Project – as the city is calling this – is nearly completed. In February or March 2014 there will be great fanfare at the completion of this project.

Video update to the Glen Canyon Park tree demolition project

Is it an improvement? Well, there is a new playground at least, but it will not be the same as it was: a steep staircase to the slide and bushes that were at the top – gone. The kids loved those; they played games of imagination and adventure there. Instead of a quirky playground that used the advantages of the site, there’s a standard-issue place that could have been built anywhere.  And the wonderful climbing tree the children loved, behind the Rec Center – also gone. The new kids will not know what they missed.

The City Arborist report stated that only 1 tree was truly hazardous, yet 42 trees were destroyed. Equally troubling is the deliberate relocation of tennis courts that destroyed 11 healthy and majestic Eucalyptus guarding the Park’s entrance.

Question: Why was there no attempt to incorporate these trees into the overall design goal that could have been achieved without sacrificing space for the playground and ball field?

Answer: San Francisco taxpayers “purchased” a native plant garden as part of the project and ensured all those “poor suitability / non-native” trees were eliminated.

Functional, Beautiful Ecosystems Should Be Left Alone; the Parks need maintenance, not destruction.

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While you are on YouTube, why not Subscribe to our Channel and keep up with our latest videos by the San Francisco Forest Alliance?

YouTubeChannel-HomePage

YouTubeChannel-HomePage

Merely follow step one or two to Subscribe to our Channel:

Step 1) Do you have a YouTube account? OK then, its easy to subscribe …just click this link http://www.youtube.com/subscription_center? add_user=SFForestAlliance

Any users who are logged into YouTube already need only to click that link and then confirm the subscription and they’ll be added to our Channel.

Step 2) Not on YouTube account yet? All you need to do is watch one of our YouTube videos, click on the”Subscribe” button / link, which is directly across from the Name of our Channel: San Francisco Forest Alliance. Or, the “subscribe” button may appear below the video title.

The last step is to sign in to your Google account or register with a Gmail, YouTube or Google+ account.

Audio Talk (YouTube) Against the Needless Destruction of Urban Forests

You are invited to hear comments by Ariane Eroy, a supporter of Sutro Forest, trees, and the environment, on KPFA radio (broadcast date: 1/2/2014).

Ariane speaks in support of the effort to save the Sutro Forest and challenges East Bay residents to get UC Berkeley to scale back its destructive project tree-removal in East Bay hills, part of a huge program that threatens half a million trees.  This 2 minute, 30 second audio broadcast includes pictures of the Mt Sutro forest.

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While you are on YouTube, why not keep up with our latest videos by the San Francisco Forest Alliance.

YouTubeChannel-HomePage

 Just follow step one or two to Subscribe to our Channel:

Step 1)  Do you have a YouTube account? OK then, its easy to subscribe …just click this link  http://www.youtube.com/subscription_center?add_user=SFForestAlliance

Any users who are logged into YouTube already need only to click that link and then confirm the subscription and they’ll be added to our Channel.

Step 2)  Not on YouTube account yet? All you need to do is watch one of our YouTube videos, click on the”Subscribe” button / link, which is directly across from the Name of our Channel: San Francisco Forest Alliance.   Or, the “subscribe” button may appear below the video title.

The last step is to sign in to your Google account or register with a Gmail, YouTube or Google+ account.

NAP Plan Paperwork Costs Over $2 Million – Not Including Implementation

Spraying pesticides in Glen Canyon March 2013San Francisco’s Recreation and Parks Commission just voted to allocate  $237 thousand from the Open Space Contingency Reserve to hire a new consultant. Its job will be just  to respond to the approximately 450 comments on the Draft Environmental Impact Report (DEIR) on the Significant Natural Resource Areas Management Plan (SNRAMP, Sin-Ramp) of the Natural Areas Program (NAP).

This will be the third consultant hired, and will bring the money spend on the Sin-Ramp – just formulating and publishing the Plan –  and the Environmental Impact Report on it to over $2 million. That is, $2 million for just the paperwork. Should the third consultant have whatever problems made the first two unsatisfactory, then of course it would mean even more money.  (The Commission seemed inclined to give them whatever they needed.)

NAP Plan Cost

(Based on information obtained from San Francisco city government)

That doesn’t include, of course, the cost of actually implementing the Sin-Ramp. Those would increase from about $1.8 million annually now to about $5.4 million annually if Sin-Ramp were implemented. Over the 20-year life of the Plan, that would mean $108 mn. And if the “Maximum Restoration” alternative were chosen, the costs would balloon to $10.8 mn per year, and over $200 million over 20 years.

Is this SF Recreation and Parks Department’s highest priority?

SNRAMP Implementation costs

Costs of implementing San Francisco’s Natural Areas Program

Glen Canyon Park: Six Months after Tree Destruction

Note: This article is re-published from SFGlenCanyon.Net

It’s been over six months since the trees were felled between Elk Rd and the Glen Canyon Rec Center.  Here’s what it looks like now.

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The destruction part took no time at all: An avenue of majestic century-old trees, a hillside habitat for birds and animals – including insect-eating bats –  a wild bee-colony,  Those were all gone in days.

The construction part is harder.

Endangered Manzanita – Reopened Comments until July 29, 2013

six-dollar franciscan manzanita

Franciscan Manzanita – Nursery specimen, six dollars

US Fish and Wildlife Service (USFWS) has reopened the comment period  for its designation of “critical habitat” for an endangered manzanita.

[You can find the Notification HERE]

This designation will likely mean significant access restrictions and possibly other unfortunate effects such as tree-removal and prescribed burns.

The new notice adds new acreage – especially around McLaren Park and Glen Canyon Park (wrongly labeled Diamond Heights) – to bring the total in Natural Areas to 203 acres (of a total of ~1100 acres of Natural Area Program land)

If you wish to comment, you can do so online HERE (look for the “comment now” button on the top right) or mail them a letter. Comments will not be anonymous. If you already sent a comment last time round, you don’t have to re-send it. It’s on record. But if you have additional thoughts, you can certainly send an additional comment.

From US FWS website:

Written Comments: You may submit written comments by one of the following methods:

(1) Electronically: Go to the Federal eRulemaking Portal: http://www.regulations.gov. Search for Docket No. FWS-R8-ES-2012-0067, which is the docket number for this rulemaking.

(2) By hard copy: Submit by U.S. mail or hand-delivery to: Public Comments Processing, Attn: FWS-R8-ES-2012-0067; Division of Policy and Directives Management; U.S. Fish and Wildlife Service; 4401 N. Fairfax Drive, MS 2042-PDM; Arlington, VA 22203.

We request that you send comments only by the methods described above. We will post all comments on http://www.regulations.gov. This generally means that we will post any personal information you provide us (see the Public Comments section below for more information). [That's at the same link.]

BACKGROUND

Some months ago, a specimen of manzanita (arctostaphylos franciscana)  – found during the Doyle Drive project in San Francisco – was declared a federal endangered species.

Though difficult to grow from seed, this manzanita is easy to clone.  You can buy plants originating from cuttings (from a different specimen of the same plant) for about $6.

The details are HERE

US Fish and Wildlife Service is in the process of designating critical habitat for this plant within San Francisco.

If this manzanita, which now has the legal status of a Federally endangered species, is planted in these areas, it will get the same protection as if it occurred there naturally. This will likely mean access restrictions; it could mean the felling of trees because this species needs full sun; and potentially might even require prescribed burns (to allow its seeds to germinate).

We wrote about that HERE.

COMMENT PERIOD REOPENED

US FWS has reopened its comment period. It discovered it was inadvertently using the wrong map, which overstated all the acreages. It’s corrected the acreage in its revised notification. It is currently asking for a total of  197 acres, of which 51 are Federal, 133 are city-owned, and 13 are private.

  • More importantly, the National Parks Service has asked for a reduction in the Federal areas, to protect its restoration efforts for other Native Plants, and also to preserve its historic forests.
  • Meanwhile, SFRPD staff have proposed an additional 73 acres to be designated as critical habitat: 56 acres in McLaren Park (which was not included earlier at all); and an additional 14 acres in “Diamond Heights” (actually, Glen Canyon and the area above O’Shaughnessy Boulevard). It’s also requested the designation of 3 acres of private land in the same area.
  • If this goes through as notified, nearly a fifth of the Natural Areas (203 acres of 1100) will be designated critical habitat for this plant – even though the plant was originally found only in four locations in San Francisco.

WHERE ARE THESE AREAS?

The colored map here broadly indicates all the areas that are to be designated as critical habitat.

Franciscan Manzanita map updated July 2013In more detail, here is the revised map for Glen Canyon. The two areas called “Subunit 9A” and “subunit 9B” are newly added to the proposed designation of critical habitat.

glen canyon updated 1

These are the two maps for McLaren Park. This park was not included in the earlier designation.

mclaren 1 sm mclaren 2 sm

WHAT DOES “CRITICAL HABITAT” MEAN?

By designating “critical habitat” the USFWS says, in essence, that these areas are so important to the conservation of the species that they must not be changed by the Federal government – or by any activity it funds or authorizes.

From the USFWS notification:

Section 3 of the Act defines critical habitat as the specific areas within the geographical area occupied by a species, at the time it is listed in accordance with the Act, on which are found those physical or biological features essential to the conservation of the species and that may require special management considerations or protection, and specific areas outside the geographical area occupied by a species at the time it is listed, upon a determination that such areas are essential for the conservation of the species.

“If the proposed rule is made final, section 7 of the Act will prohibit destruction or adverse modification of critical habitat by any activity funded, authorized, or carried out by any Federal agency. Federal agencies proposing actions affecting critical habitat must consult with us on the effects of their proposed actions, under section 7(a)(2) of the Act.”

If these “endangered” plants are introduced, we can expect that the Natural Areas Program will want to protect them. This may mean:

  • Restricting access (perhaps with fencing);
  • Cut down any trees shading the plants since they require full sun; and
  • Maybe even seek to get permission for prescribed burns, since it’s possible the Franciscan manzanita needs fire to germinate. (This is believed true of the closely-related Raven’s manzanita.)

It will also mean that the area cannot be planted with anything that clashes with the manzanita in its requirements – including large shrubs and bushes (even if native). It will probably mean more pesticide use, to keep other plants from encroaching on the area where they’re trying to grow this one.

WHAT IS THIS PLANT AND IS IT ENDANGERED?

We mentioned before that Franciscan manzanita plants, grown from cuttings of another specimen, have been available in plant nurseries for some 50 years.   This plant, the Doyle Drive manzanita, is presumed to be a different individual of the same species. If so, this is good because it would add a little genetic diversity. However, until someone does a DNA analysis, we cannot tell if it’s true.

  • It could be a nursery plant that someone introduced; the neighboring plants were non-native and very likely deliberately planted. In that case, it will be genetically identical to the others.

  • It could be a cross with another manzanita species. Manzanitas generally hybridize really easily, and some scientists think this is a cross between Franciscan manzanita and arctostaphylos uva-ursi.

It’s complicated with manzanitas. They adapt to any little change in their environment, and they are easily crossed with other manzanita species. As a result, scientists often have to re-define which are species, which are subspecies, and which are mistakenly considered a separate species when they’re not.

WHAT ARE ITS CHANCES?

There’s a closely-related  manzanita species, Raven’s manzanita, that is also as endangered. For over 30 years now – and an estimated $23 million – people have been trying to bring it back. The definition of success would be two generations of plants produced from seed (not cuttings) and some spontaneous populations in the wild. That’s not much of a target to achieve – but it isn’t happening.

So with all the time, trouble, and expenditure – what are the chances of the closely-related Franciscan manzanita succeeding?

Franciscan manzanita

Franciscan manzanita

Glen Park Tree Demolition – Day 5 Video

The line of grand old eucalyptus at the entrance of Glen Canyon Park is gone now. This is the picture on Day 5, courtesy Ron Proctor:

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There are more trees being felled, over 40 more in this project alone, but we need a break from observing the tragic destruction. Our next post will be a more hopeful one.

Downed Oak, Mount Davidson, and “Poor Suitability”

Downed oak on Mt Davidson

We’ve been hearing a lot about “poor suitability” in the context of trees that San Francisco Recreation and Parks Department (SFRPD) wants to cut down in Glen Canyon Park. Have they considered the “poor suitability” of the trees they might be planting?

Besides being extremely slow-growing and highly allergenic (because of their fine, wind-borne pollen), the native oak trees seem to have a hard time surviving in our windy city.

Picture 005 downed oak on Mt DavidsonA neighbor reports:

“One of the five oak trees planted to replace the 100 plus eucalyptus and cypress destroyed in 2008 by the SFPUC water pipe project (to avoid the native plant area on Mt.Davidson) fell in the recent severe wind storm.

“Perhaps this is why oaks never grew on this hill? Even when sheltered by the sturdy M Davidson forest, this species is challenged to survive the winter winds and appears to be poorly suited for this location.”

 

Natural Areas Plan: SFFA comments on the DEIR (Pt 6: Flawed Process)

Whatever one thinks of the Significant Natural Resource Areas Management Program (SNRAMP, Sin-ramp) – and this website has documented what we do think about it –  it’s important that the public is kept informed. They should be able to know about it, understand it, and be free to comment on it.

Unfortunately, the city hasn’t been doing a really good job about letting the public know. They have done the bare minimum: Posting a notice (like the one in the picture) in the SF Examiner and at McLaren Lodge, and mailing those who were already on their mailing list.

People have to go looking for the Sin-ramp and the Draft Environmental Impact Report (DEIR). And then – things keep changing, and only those who are really alert are aware of the changes.

On top of that, there’s a big fat glaring error right at the start of the DEIR.

Read on for details. (Please note we’ll be uploading attachments later on.)

The public review and comment process for the Draft Environmental Impact Report (DEIR) for the Significant Natural Areas Resources Management Plant (SNRAMP) was severely compromised by:

  • A major mistake in the identification of the “Environmentally Superior Alternative” and the refusal to correct that mistake during the public process
  • The last minute rescheduling of the public hearing by the Planning Commission which prevented many concerned citizens from commenting at that hearing
  • The refusal to inform the public of the extension of the deadline to October 31, 2011
  • The refusal to inform the public of the reopening of the public comment period to June 11, 2012

These errors and policy decisions will materially prejudice the public comment and therefore expose the DEIR to a legal challenge that will require that the process be repeated.

1.    THE REFUSAL TO CORRECT THE MISTAKE IN THE DEIR ABOUT THE “ENVIRONMENTALLY SUPERIOR ALTERNATIVE”

The Summary of the DEIR at the beginning of the document says that the “Maximum Restoration Alternative” is the “Environmentally Superior Alternative” (page 2).  This is a mistake.  The “Maximum Restoration Alternative” is NOT the “Environmentally Superior Alternative.”   The “Environmentally Superior Alternative” is the “Maintenance Alternative.”  The correct statement does not appear in the DEIR until the very end of the document:

The Maximum Recreation and Maintenance Alternatives are the environmentally superior alternatives because they have fewer unmitigated significant impacts than either the proposed project or the Maximum Restoration Alternative. Between the Maximum Recreation Alternative and the Maintenance Alternative, the Maintenance Alternative would be the environmentally superior alternative for two reasons. While the two alternatives have the same number of significant and unavoidable impacts under CEQA, the Maintenance Alternative has fewer potential environmental effects than the Maximum Recreation Alternative. First, the Maintenance Alternative would not create new trails, the construction of which could result in impacts to sensitive habitats and other biological resources. Second, over time the Maximum Recreation Alternative would result in Natural Areas with less native plant and animal habitat and a greater amount of nonnative urban forest coverage. The Maintenance Alternative, on the other hand, would preserve the existing distribution and extent of biological resources, including sensitive habitats. For these reasons, the Maintenance Alternative is the environmentally superior alternative.” (DEIR, page 525-526) (emphasis added)

Attached is the email correspondence with Jessica Range, the staff member in the Planning Department responsible for the environmental review process, about this error.  Ms. Range acknowledges the error, confirms that the “Environmentally Superior Alternative” is the “Maintenance Alternative,” but refuses to correct the error until the public comment period is over. (See Attachment VI-A) [We will be uploading all attachments later on.]

Few readers will read a document that is over 500 pages long.  This mistake will therefore mislead the public into supporting the “Maximum Restoration Alternative” which expands the destructive and restrictive aspects of the Natural Areas Program.  Furthermore, and perhaps more importantly, this expansion is NOT legal because it violates the requirements of the California Environmental Quality Act (CEQA), which requires that the “Environmentally Superior Alternative” has the least negative impact on the environment of all proposed alternatives:

“§21002.  APPROVAL OF PROJECTS; FEASIBLE ALTERNATIVE OR MITIGATION MEASURES
The Legislature finds and declares that it is the policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects, and that the procedures required by this division are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.”  CEQA Guidelines, page 2 (emphasis added)

This mistake will profoundly prejudice the public review and comment period.  The mistake was exacerbated by the refusal to correct the mistake before the public process was complete.

Although the mistake was verbally acknowledged by the staff of the Planning Department at the beginning of the public hearing on October 6th, it was characterized as a “typographical error.”  The dictionary definition of “typographical error” is:  “an error in printed or typewritten material resulting from a mistake in typing or from mechanical failure or the like.”   [Ref: Webster’s Collegiate Dictionary, Random House, 1991] It is an insult to the public’s intelligence to characterize the substitution of an entire phrase (“Maximum Restoration Alternative”) for another (“Maintenance Alternative”) as a typographical error.   Trivializing this error further misleads the public by failing to acknowledge the substantive differences between these alternatives.  The “Maintenance Alternative” is at the opposite extreme from the “Maximum Restoration Alternative” in the range of alternatives.

The “Maximum Restoration Alternative” proposes an expansion of the active restoration efforts of the Natural Areas Program to 100% of all acreage designated as “natural areas.”  This represents a 73% increase in the acres subjected to tree removals, herbicide applications, recreational access restrictions, and the planting of endangered plants and animals that could potentially require further access restrictions.

In addition to the inaccurate and misleading identification of the environmentally superior alternative, the public notice of the DEIR was inadequate.  No mention was made in the original public notice of the locations of the natural areas that would be impacted by the implementation of SNRAMP.  No mention was made of the significant impacts on the environment such as the removal of thousands of trees or the loss of recreational access.  The public notice did not enable the public to understand that the implementation of SNRAMP would have a significant impact on their parks or their neighborhoods.

2.    THE PUBLIC HEARING FOR THE DEIR LIMITED PUBLIC COMMENT

The public review and comment process was further compromised by the last minute decision to hold the public hearing by the Planning Commission earlier than originally announced.  The public hearing was originally announced to begin at 1:30 pm on October 6th.  Shortly before the hearing, the starting time was moved up to noon.

The public was further confused about the timing of their opportunity to speak to the Commission about the DEIR by the placement of the item on the agenda.  The DEIR for the SNRAMP was item number 13 on an agenda with 19 items.  The public had no way of knowing when the 13th item would be heard.  Many naturally assumed that it would not be at the beginning of the hearing.  They were wrong.

The public comment period on the DEIR for the SNRAMP was completed by 2 pm.  Many people came to the hearing, hoping to speak, only to find that they had missed the opportunity to do so.

A few people arrived in time to speak, but didn’t arrive in time to hear the staff of the Planning Department acknowledge the mistake about the “Environmentally Superior Alternative.”  Therefore, they wasted their public comment by focusing on an error that the Planning Department had made a commitment to correct.  No one showed them the courtesy of telling them during the hearing that the error would be corrected.

There are many neighbors of the so-called “natural areas” who have been following this issue for 15 years.  They were deeply committed to speaking and they were deprived of the opportunity to do so by the change in the time of the hearing.

3.   THE PUBLIC WAS NOT ADEQUATELY INFORMED OF THE EXTENSION OF THE DEADLINE FOR COMMENT

The President of the Planning Commission requested at the public hearing on October 6th that the deadline for written public comments be extended to October 31st.  No effort was made to inform the public of this extension of the deadline.  The Planning Department was asked (in writing) to inform any member of the public that had been informed of the original deadline of October 17th of this extension.  That request was refused.

Such refusal to provide the public with notification of the extension of the deadline will further compromise the public review process.

4.  THE PUBLIC WAS NOT ADRQUATELY INFORMED OF THE RE-OPENING OF THE PUBLIC COMMENT PERIOD

The San Francisco Forest Alliance learned (from a neighborhood association) that the public comment on the DEIR was reopened on April 27, 2012 about one week after the notice was mailed.    SFFA immediately requested that this public notice be distributed more widely to the neighbors of the natural areas and posted in the natural areas.  This request was refused.

According to the mailing list that was used to distribute the notice of the reopening of the public comment period, the same neighborhood associations that were notified of the first public comment period were notified again.  The second public comment period was not more widely distributed than the first.  The organizations that had an opportunity to comment in October 2011 were essentially given a second opportunity to comment.   This is preferential treatment that will further jeopardize the fairness of the public process.

The reopening of the public comment period was another opportunity for the DEIR to be corrected.  The incorrect statement on page 2 of the DEIR stating that the Maximum Restoration Alternative is the Environmentally Superior Alternative was not corrected when the public comment period was reopened.  That incorrect statement was simply redistributed and reposted to the Planning Department website.  Once again, the refusal to correct this statement will prejudice the public comment.

Conclusion

The public review and comment process was severely compromised by a serious mistake and by several actions of the Planning Department staff.  The appropriate legal remedies for these mistakes are:

  • Correct the DEIR by accurately identifying the “Environmentally Superior Alternative”
  • Distribute the corrected DEIR in the same manner as the original was distributed
  • Announce another public hearing along with the corrected DEIR
  • Announce another deadline for written public comments that is at least as long as the original period
  • Distribute the public notice regarding the new public comment period to the neighbors of the natural areas and post the public notice in the natural areas.

The public review and comment period for the DEIR for the SNRAMP has been a stunning display of unfair dealing with the taxpayers who are paying for this project.  It is experiences such as this that turn taxpayers into protesters.

Natural Areas Plan: SFFA comments on the DEIR (Pt 5: Supporting the “Maintenance Alternative”)

In the Draft Environmental Impact Report (DEIR) on the Significant Natural Resource Areas Management Plan (SNRAMP), considered 4 alternatives to the SNRAMP:

(1) No Project – which would mean NAP would continue doing what they planned under an earlier plan, the 1995 plan;

(2) Maximum Restoration – which would mean converting the entire 1100 acres under the Natural Areas Program to scrub and grassland, and putting in access restrictions;

(3) Maximum Recreation – maximizing recreation except where it interferes with existing native plants and federally-protected species;

(4) Maintenance – Maintain the current distribution of native and non-native species in the Natural Areas; no habitat conversion.

The 4th alternative, The Maintenance Alternative,  is also the Environmentally Superior Alternative since it will have the least negative impact on the environment. This is the alternative that SFFA supports (though actually, closing down NAP would be even better).

In the body of the DEIR, it properly identifies the Maintenance alternative as environmentally superior.) However, the summary wrongly states that the Maximum Restoration alternative – which would be environmentally devastating – is the “environmentally superior alternative.”

Read on for the discussion of these issues.

The Draft Environmental Impact Report (DEIR) identifies the Maintenance Alternative as the Environmentally Superior Alternative.   This is consistent with CEQA law which requires that the alternative that will have the least negative impact on the environment be identified as the Environmentally Superior Alternative.

(This assumes that page 2 is corrected to be consistent with pages 525-526, as the Planning Department has said in writing that it will be corrected in the final EIR.)

Our support for the Maintenance Alternative is based on the fact that it is the least destructive of the alternatives presented by the DEIR:

  • The Maintenance Alternative will destroy the least number of trees and existing vegetation
  • The Maintenance Alternative will require the least amount of pesticide
  • The Maintenance Alternative will require the least restrictions on recreational access
  • In addition to being the Environmentally Superior Alternative, the Maintenance Alternative is also the only viable and sustainable alternative because:
  •   The Maintenance Alternative will not require that native plants which are no longer adapted to present conditions be planted where they will not grow
  • The Maintenance Alternative will not require that the City of San Francisco substantially increase the budget of the Natural Areas Program so that native plant gardens can be expanded

1.    THE MAINTENANCE ALTERNATIVE WILL HAVE LESS NEGATIVE IMPACT ON THE ENVIRONMENT

The Natural Areas Program (NAP) has destroyed hundreds of trees in the “natural areas” in the past 15 years.  The destruction of these trees has given NAP the opportunity to demonstrate that removing trees is beneficial to native plants.  In fact, there is little evidence that the destruction of trees has resulted in successful native plant gardens.

The Pine Lake “natural area” is an example of the destruction of trees which did not result in a successful native plant garden.  In 2004, about 25 trees were destroyed at the western end of Pine Lake.  This destruction is documented by the Hort Science report of December 2011 (“Stern Grove-Pine Lake Park, Parkside Square tree risk assessment”). This report was written as an update on Hort Science’s comprehensive assessment of all trees in Stern Grove-Pine Lake in 2003, in preparation for finally removing the hundreds of trees that had been evaluated as hazardous 8 years before.  Here is what Hort Science found at the “West end of the park, near Wawona and 33rd Ave:” “This area had a number of trees removed by the Natural Areas Program.

The area in which the trees were destroyed was then planted with native plants and surrounded by the limbs of the trees that were destroyed.  This is what that garden looked like in May 2008, four years later:

West end of Pine Lake, May 2008

And this is what that area looks like now:

West end of Pine Lake, July 2011

Little remains from that effort.   This is not an isolated example of the results of 15 years of attempting to restore native plants in places where they have not existed for over 100 years.  In addition to the 25 healthy trees that were destroyed at the western end of Pine Lake, 132 trees judged as hazardous were destroyed around the lake in 2006 (these tree removals are documented in SNRAMP). The southern and northern shores of Pine Lake have been planted repeatedly.  These areas are now dominated by foxtails and non-native nasturtiums which are thriving, despite being eradicated repeatedly.

Other parks have had similar experiences in their “natural areas.”  Sometimes toxic herbicides are used in the attempts to eradicate the non-native plants.  Here is a picture of a field of oxalis and mustard in Glen Canyon Park that has been sprayed with toxic Garlon numerous times.  There is no evidence that these non-native plants have been defeated by this chemical warfare.

Oxalis in Glen Canyon Park, February 2011

According to “UC [Davis] IPM Online” , Garlon only poisons the visible part of the plant; it doesn’t kill the root of the plant (in this case, the “bulbil”). So, the plant grows back the next year and is poisoned again.  Between March and October 2010, the Natural Areas Program and its contractors (Shelterbelt Builders) sprayed Glen Canyon with herbicides 10 times.  If this futile effort continues, it will be sprayed again every year, for as long as the public is willing to tolerate this poisoning of its public parks.  There is a creek at the bottom of this canyon that is probably being poisoned as well.  According to the federally mandated Material Safety Data Sheet for Garlon, it is “highly toxic” to aquatic life.  Alongside the creek is a day camp that is attended by children year around.   Do their parents realize that this toxic chemical is being sprayed repeatedly in proximity of their children?

More fortunate “natural areas” have essentially been abandoned by the Natural Areas Program.  Tank Hill has not been gardened by the NAP staff for several years.  It has been spared the spraying of herbicides.  However, it is visited by an unsupervised volunteer who hacks at the trees that remain.  In other words, so many acres of parkland have been designated as “natural areas” that the staff is unable to garden them and is unable to supervise the volunteers who are free to do whatever they want in them, including mutilate trees.

2.    THE CONDITIONS THAT SUPPORTED NATIVE PLANTS IN SAN FRANCISCO HAVE CHANGED

One of many questions that was asked during the public comment period for the Initial Study was:  is it still possible to sustain native plant gardens in San Francisco, given the radical changes in underlying conditions, e.g., higher levels of Carbon Dioxide, higher temperatures resulting from climate change and urban heat effect, changes in soil such as increased nitrogen levels and as a result of non-native vegetation, etc.?

This is one of many questions that were raised at the time of the Initial Study that are neither acknowledged nor answered by the DEIR.  We will therefore ask and answer this question because it is our last opportunity to do so.  The evidence that the ranges of native plants and animals have changed is overwhelming.  We should not be surprised that the Natural Areas Program has had little success in achieving their goals after 15 years of effort.  NAP and its supporters would like the public and the City’s policy makers to believe that its lack of success is because they are not adequately funded.

Even if the City had the resources to substantially increase the staff of the Natural Areas Program—and chose to use them for that purpose–we would not see a substantially different outcome from their efforts.  To demonstrate the futility of this effort, we turn to the living roof on the California Academy of Sciences.

When the California Academy of Sciences reopened in Golden Gate Park in August 2008, its “living roof” was considered its most unique feature.  Thirty species of native plants were candidates for planting on the roof.  They were planted in test plots with conditions similar to the planned roof and monitored closely.  Only nine species of native plants were selected for planting on the roof because they were the only plants that were capable of self-sowing from one season to the next, implying that they were “sustainable.”  A living demonstration of “sustainability” was said to be the purpose of the living roof.

So what have we learned from the living roof about the sustainability of native plants in San Francisco?  Two of three of the predominant species on the roof after 2-1/2 years were native.  The third—moss–is a “cosmopolitan” species that occurs everywhere.  It is not considered native or non-native.  It was not planted on the roof and therefore should be considered “invasive” in this context.  The Academy’s monitoring project has divided the roof into four quadrants.  By February 2011, non-natives outnumbered natives in two of the quadrants.  Although natives outnumbered non-natives in the other two quadrants which are actively gardened, non-natives were also growing in these quadrants.

The consultant hired by the Academy to plan the roof garden, Rana Nursery, advised the Academy to walk the streets of San Francisco and identify the plants growing from the cracks in the sidewalks.  These are the plants he advised the academy to plant because these are the plants that are adapted to current conditions in the city.  The academy rejected this advice because they were committed to planting exclusively natives on the roof.

The designer also advised the academy not to irrigate the roof, because the point of the roof is that it is a demonstration of sustainability.  Again, the academy refused because they knew that without irrigation most of the native plants would be brown during the dry season, roughly half the year.  (In fact, it is not clear that the plants would even survive without irrigation.)  They wanted the public to believe that the plants that are native to San Francisco are beautiful year around.
There is a lesson here for anyone who is willing to learn from it.  The living roof is not natural because it is irrigated and intensively gardened (e.g., weeded, fertilized, replanted, reseeded, etc. ), yet non-natives not only found their way there on their own, but were dominating it within only 2-1/2 years.  Native plants are not sustainable in San Francisco without intensive gardening effort.  The living roof on the Academy is a tiny fraction of the acres that have been designated as “natural areas.”  The Academy is one building in Golden Gate Park.  All of Golden Gate Park is about the same acreage as all of the 1,100 acres of “natural areas.”

Peter Del Tredici has been telling us this for several years.  He is a Senior Research Scientist at the Arnold Arboretum at Harvard University and a Lecturer in the Department of Landscape Architecture at the Harvard Graduate School of Design.

In a recent publication, he advises the managers of public lands in urban areas to abandon their fantasy that native plants are sustainable in urban settings:

The notion that self-sustaining, historically accurate plant associations can be restored to urban areas is an idea with little credibility in light of the facts that 1) the density of the human populations and the infrastructure necessary to support it have led to the removal of the original vegetation, 2) the abiotic growing conditions of urban areas are completely different from what they were originally; and 3) the large number of non-native species that have naturalized in cities provide intense competition for the native species that grew there prior to urbanization.”

(Ref: “Spontaneous Urban Vegetation:  Reflections of Change in a Globalized World,” Nature and Culture. Winter 2010, 209-315.)

Sure, he says, we can grow native plants, but they require at least the same amount of effort as growing any other plant and are therefore just another form of gardening:  “Certainly people can plant native species in the city, but few of them will thrive unless they are provided with the appropriate soil and are maintained to the same level as other intentionally cultivated plants.”

He concludes that native plant advocates are making a “cultural value judgment:”

“…people are looking at the plant through the subjective lens of a cultural value judgment which places a higher value on the nativity of a given plant than on its ecological function.  While this privileging of nativity may be appropriate and necessary for preserving large wilderness areas or rare native species it seems at odds with the realities of urban systems, where social and ecological functionality typically take priority over the restoration of historic ecosystems.”

So here is our conclusion:

Conclusion

Although the Maintenance Alternative is the least destructive of the alternatives considered by the DEIR, the closure of the Natural Areas Program would be less destructive than the Maintenance Alternative.

  • The Natural Areas Program has had 15 years to demonstrate that destroying trees and spraying our parks with herbicides will enable them to recreate sustainable native plant gardens.  They have failed.
  •   NAP has little to show for the destruction of hundreds of healthy trees, the use of gallons of toxic herbicides, and the investment of millions of dollars of taxpayers’ money.
  • At a time of extreme economic sacrifice, it is unseemly to suggest that further destruction of trees, poisons spread and money squandered would be worthwhile.
  •   Furthermore, greater sacrifice of money, trees, public safety, and recreational access will not result in sustainable native plant gardens.

The environmental impacts of the Proposed Project, No Project, and Maximum Restoration Alternatives are significant and the final EIR must judge them as such in these categories:  Aesthetics, Wind and Shadow, Recreation, Biological Resources, Hydrology and Water Quality, Hazards and Hazardous Materials, and Air Quality.

NAP Lops Off Tree Limbs In The Middle Of Nesting Season

Two of the three Great Horned Baby Owlets, taken on April 28, 2012

Three weeks ago, at a meeting with Recreation and Parks Department Director Phil Ginsburg and Natural Areas Program Director Lisa Wayne, we asked why there had been a huge amount of clearing in Glen Canyon Park during the denning and nesting season — wasn’t this in violation of the grant which stipulated specifically that work must be confined to Summer and Fall when the animals were not nesting?  The nesting season runs from Winter through the Spring, yet clearing and toxic herbicides have been applied continuously from November through April in Glen Canyon Park. See Nesting Bewick’s Wren in a “Naturalized Area”. Phil Ginsburg didn’t know the answer, but he assumed Lisa Wayne would give a good answer. But she had no good explanation, only a bad one. Lisa admitted that she broke the rules in order not to lose funds from a grant that was about to expire.

One would have thought that with our reminder during that meeting on April 6th, this breach might not be made again. But no. Yesterday, April 27th, there were at least five trucks with tree-cutting equipment in that park. There was also a sign: “tree work”.  Visitors to the park at first were deceptively relieved when they heard that trees were simply going to be trimmed — they were not going to actually be cut down. But few had thought the issue through: This is nesting season. Everyone who knows anything about wildlife knows that you don’t interfere with habitat when animals are raising their young.

We don’t know how many birds were displaced, nor how many nests were destroyed. We do know that lopping off limbs occurred within less than 100 feet of our owl family — there was tremendous noise, and tremendous activity. The owl triplets nesting in the crook of a Eucalyptus tree have not fledged — they cannot fly yet. And the Red Tail Hawks, though further away, are still sitting on their eggs. Countless songbirds live in these trees. Nesting season is in full swing. This activity should be protested to your Supervisors, the Parks Commissioners and to the Recreation and Parks Department.

West Portal Monthly: Neighbors Mobilize to Save Mt Davidson from the Axe

West Portal Monthly ran Jacquie Proctor’s article about the San Francisco Forest Alliance’s petition on its front page. Headlined “Neighbors Mobilize to Save Mt Davidson from the Axe,” the article explained how the petition drive is planned to end with signatures being submitted to the city on Arbor Day –  April 27th.  Unfortunately, the paper isn’t online, so we can’t link to it. (If you want to see the article below larger, click on it, then click again on the image that comes up.)

If you haven’t signed the petition already, and would like to do so, here’s the button:

San Francisco Examiner: Trail proposal at San Francisco’s Twin Peaks up for debate

Some time ago, we’d posted here about the wonderful twisted willow trees in the “Outback Trail” in Glen Canyon Park that are threatened with removal. Recently, we learned about the “Creek to Peaks” trail planned to connect Glen Canyon to Twin Peaks.

At present, it looks as though the planned trail would drive right through this unusual and beloved trail, completely destroying its quirky character.

The San Francisco Examiner interviewed an SF Forest Alliance member about it. Janet Kessler pointed out that the trail did not need to go through this very special area or destroy habitat on which the wildlife of the canyon depend.

Read the whole story here.

West Portal Monthly: Clearcut Case of Overkill at Mt Davidson Park

The West Portal Monthly today published an article by Jacquie Proctor explaining the problem of the NAP specifically at Mt Davidson and generally throughout the city.  The plan seeks to destroy at least 1600 trees on Mt Davidson alone. Read on:

Mt. Davidson Park – An Open Space Preserved for Recreation or Native Plants?

Native plant interests threaten trees throughout the city, and in particular, in one of San Francisco’s significant century-old forests: Mt Davidson. A favorite area for the residents of Miraloma Park, the Significant Natural Areas Management Plan calls for felling over 1600 trees.

Photo credit: Peter Earl McCollough

In the map below, the brown areas would be… well, brown. At least in summer. They are to be turned over to native plants.

This diagram is reproduced from public documents of the city of San Francisco, and used here for the purpose of discussion and education.

The article below by Jacqueline Proctor was published in Miraloma Life in November 2011, and is republished here with permission and added emphasis. [ETA: The publication followed up with an even longer article by Dan Liberthson.]

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Mt. Davidson Park – An Open Space Preserved for Recreation or Native Plants?
By Jacqueline Proctor

In 1995, the City transferred Mt. Davidson Park to the Natural Areas Program with the result that protection and restoration of native plants—rather than public recreation, aesthetics, or forest maintenance—has become the first priority of the few City staff assigned to maintain the park. A recently completed Draft EIR has determined that the Natural Areas Program Plan will have a significant impact on the environment. Indeed, the Plan envisions the negative consequences to public enjoyment of the Park to be beneficial.

While the City is busy planting 1000s of street and median trees to “clean the air,” it is giving the OK to spend limited Recreation and Park funds to cut down 1000s of the historic trees along the trail and road areas of Mt. Davidson, restrict public access through native plants areas by installing barriers, prohibiting benches in the best view areas, and fostering the growth of poison oak (a native plant now thriving where non-native shrubs and trees have already been removed).

The Miraloma Park Improvement Club Board plans a letter to the City advocating for the Final EIR to recommend preservation of the forest as an historic, natural, recreational, and aesthetic resource, as well as advocating for full access to the native plant area and installation of benches in the view areas.

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(The Board did write such a letter in comments to the Draft Environmental Impact Report on the SNRAMP.)

Recently, the Wall Street Journal covered this in its December 15th 2011 issue; and the San Francisco Examiner had an article about it on the same day. The San Francisco Forest Alliance (SFFA) has links to both articles on its Facebook page. Click here for WSJ, and here for the article in the Examiner.

The picture at the top of this post is the one used in the Wall Street Journal article. It’s reproduced here with permission from photographer Peter Earl McCollough, who also provided the the picture in the article by Jacqueline Proctor.  (His photography website is at www.petermccollough.com )

The Season for Pesticides on “Natural” Areas

And when is it not, actually?

Maybe this could be called the Santa Claus mix? The old formula – Glyphosate and Imazapyr, being used against “Road brush” whatever that is, and erhata grass. It’s scheduled for Dec 19-23, 2011.

Pesticides infest the “natural” areas of the SF Rec & Park… the “Significant Natural Resource Areas.”

(Incidentally, the phone number on the notice seems to be wrong. If you want to call Mr Montana, this may work better: Ralph Montana of IPM (415) 831-63o6)

It’s beginning to look a lot like Christmas, everywhere you go. Except Twin Peaks.

[Reproduced with permission from SutroForest.com]

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